PROGRAM COMPLIANCEAFTERSCHOOL SNACK PROGRAM, FRESH FRUIT AND VEGETABLE PROGRAM, AND THE SPECIAL MILK PROGRAM

PRESENTED BY: EDWARD COLEMAN FEBRUARY 18, 2016

EDUCATION CODES: 3000 ADMINISTRATION, 3110 ELIGIBILITY, 3200 PROGRAM MANAGEMENT, 3310 MEAL COUNTING AND CLAIMING, AND 3320 COMPLIANCE WITH REGULATIONS

WEBINAR OUTLINE

• Afterschool Snack Program (ASP)• Fresh Fruit and Vegetable Program (FFVP)• The Special Milk Program (SMP)

THE AFTERSCHOOL SNACK PROGRAM (ASP)

The Afterschool Snack Program allows participating schools to serve students nutritionally balanced snacks while also providing appropriate activities.

• School Eligibility

• Program Documentation

• Counting and Claiming System

• Snacks Nutritional Requirements

• Educational or Enrichment Activity

• Food Safety and Civil Rights

SCHOOL ELIGIBILITY I. Area Eligible Sites: These are locations within the geographical area of a school in which at least 50%

of enrolled students are certified for free or reduced priced meals. Snacks under this option are served free to all children and reimbursed at the free rate for snacks.

II. Non- Area Eligible Sites: The snacks at these sites are served at the free, reduced, or paid rates for snacks. The rate each child pays is based on approved eligibility such as income applications, direct certifications, etc.

As a note Non- Area Eligible Sites must maintain the documentation used to establish a child's eligibility as this documentation would be reviewed as part of an Administrative Review.

AFTERSCHOOL SNACK PROGRAM DOCUMENTATION The SFA/RCCI must maintain documentation that substantiates its claims for reimbursement appropriate documentation includes but is not limited to the following;

• Daily Production Records

• Daily Count Sheets/Rosters

• Consolidated Count Sheets

• Delivery Invoices

• Benefits Issuance Roster with correct eligibility determinations for each child

• http://nutrition.nv.gov/layouts/Page_Style_1.aspx?id=8674

COUNTING AND CLAIMINGThe counting and claiming system that SFA’s and RCCI’s have in place must ensure that snacks are counted, recorded, consolidated and reported through a system that consistently yields correct claims. This system should ensure the following;

• Each eligible child only receives one reimbursable snack per snack service.

• The reimbursable snack is only counted when it is served to the child at the point of service.

• Children are able to participate in this program until they turn 18 or until the end of the school year if they turned 19 during the current school year. • NOTE: Children determined to have mental or physical disability are not subject to the age limit requirement.

• Adult snacks including snack served to children because of age limits are counted separately since they are not reimbursable.

SNACK NUTRITIONAL REQUIREMENTSA reimbursable snack consists of two of the following four components

1. Milk (flavored or unflavored fat free or unflavored low fat)

2. Fruit or Vegetable

3. Grains

4. Meat/ Meat Alternate

Daily Production Records should indicate the quantities offered to each age/grade group (See page I-15 of the Food Buying Guide)

The Snack menu for the month should be posted

Examples of Allowable Snacks: Whole Wheat Gold Fish and Fat Free Flavored Milk, String Cheese and Apples or A Whole Grain Hot Pocket

EDUCATIONAL OR ENRICHMENT ACTIVITYAs part of the Afterschool Snack Program, SFA’s that offer the program must also offer an educational/ enrichment activity along with the snack. The activity should meet the following guidelines;

• It must be a structured and organized event

• It must be educational or enriching in nature

• It cannot be a purely athletic pursuit (like a little league team, organized athletic events such as baseball games or basketball games)

Examples: arts/music activities, homework assistance, reading room/library, mentoring, life skills, counseling, study hall

AFTERSCHOOL SNACK PROGRAM SELF MONITORINGFederal regulations require that the Afterschool Snack Program be monitored two times per year.

The first time the program must be monitored is within the first four weeks that the Afterschool Snack Program begins each year.

The second time it must be monitored is before the end of the school year.

For SFA’s that have school year round, the program would begin with each new fiscal year.

FOOD SAFETY AND CIVIL RIGHTS The Afterschool Snack Program must adhere to the following Food Safety requirements

• HAACP principles in handling food must be followed; • http://sop.nfsmi.org/sop_list.php

• Most Recent Food Safety Inspection must be posted

• A system to handle special diets

• Up to date Temperature Logs

The Afterschool Snack Program must adhere to the following Civil Rights requirements:

• Have a policy for collecting ethnic and racial data

• “And Justice for All” posters must be prominently displayed

• A Civil Rights policy that meets standard program requirements

• Annual Civil Rights training; • http://nvcnp.doe.nv.gov/frameManager.aspx

THE FRESH FRUIT AND VEGETABLE PROGRAM (FFVP)The Fresh Fruit and Vegetable Program (FFVP) seeks to increase children's exposure to and consumption of a variety of fruits and vegetables.

• Claim Documentation

• Claim Validation

• Buy American Provision

• Program Guidelines for the FFVP

• Food Guidelines for FFVP

• The Nutritional Education Component

Resources: http://www.fns.usda.gov/ffvp/fns-resources, http://www.fns.usda.gov/sites/default/files/handbook.pdf

CLAIM DOCUMENTATION

The following documentation can be used to substantiate the claims for reimbursement;

• Invoices for produce

• Invoices for products used in the food service (napkins, utensils, etc.)

• Clear documentation of worker time spent in the program

• Clear documentation of the year to date administrative costs charged to the program

• Documentation supporting the costs of equipment bought for the program

CLAIM VALIDATION

General Guidelines; for more in depth information please see our webinar;

http://www.slideshare.net/NevadaAgriculture/fresh-fruit-and-vegetable-program-webinar-from-the-nevada-department-of-agriculture-2014

THE BUY AMERICAN PROVISION SFA’s that participate in the FFVP must also adhere to the Buy American Provision. The Provision, CFR 210.21 (d)(1) through (d)(2)(ii), describes the criteria of what constitutes a domestic commodity or product.

• An agricultural commodity that is produced in the US

• A food product that is processed in the US substantially using agricultural commodities that are produced in the US.

1. To qualify as domestic over 51% of the final processed product consists of agricultural commodities that were grown domestically.

Exceptions to the Buy American Provision

• The product is not produced or manufactured in the US in sufficient and reasonably available quantities of a satisfactory quality

• Competitive bid reveals the costs of a US product is significantly higher than a foreign product

PROGRAM GUIDELINES FOR FFVPThe following guidelines are specific to the Fresh Fruit and Vegetable Program;

• The program must occur at least 2 times a week for all students

• The program must offer a variety of fruits and vegetables

• REPEAT OFFERINGS ALLOWED

• THINK SEASONAL AND LOCAL WHEN POSSIBLE

• Servings do not have to be full portions

FOOD GUIDELINES FOR FFVP

The foods served during the FFVP must adhere to the following guidelines;

• The following foods are not allowed as part of the FFVP; frozen, canned, dried, and other types of processed fruits, fruit/vegetable juice, nuts, cottage cheese, trail mix, fruit or vegetable pizza, smoothies, fruit strips, drops, or leather.

• Cooked vegetables may not be offered more than once per week and only when included as part of a nutrition education lesson

• Dip may be provided for vegetables but it must be low fat or fat free and no larger that 2 tablespoons

THE NUTRITIONAL EDUCATION COMPONENTThis nutritional educational component must be a part of every FFVP service. The link below provides additional information in general on the FFVP.

Resources

• USDA toolkit• http://www.fns.usda.gov/ffvp/ffvp-toolkit

• Harvest of the Month—Fruit and Veggie info sheets

• http://harvestofthemonth.cdph.ca.gov/Pages/Downloads.aspx

• http://www.massfarmtoschool.org/programs/harvest-of-the-month/

• http://idahopreferred.com/farm-to-school/posters/

• http://www.sdharvestofthemonth.org/

THE SPECIAL MILK PROGRAM (SMP)The Special Milk Program provides milk to children in schools, nonprofit RCCI’s, and eligible camps that do not participate in other Federal child nutrition meal service programs.

• The Public Release

• The Pricing Policy

• SMP Options

• Counting and Claiming

• Program Compliance

• Recordkeeping

THE PUBLIC RELEASE • Must be announced near the beginning of

the school year

• Must include the eligibility criteria for free milk

• Must contain the Income Eligibility guidelines for Free Milk Only

• Must be provided to local media, the unemployment office, and employers contemplating large layoffs

THE PRICING POLICY

SFA’s operating the SMP must price their milk in accordance with Food and Nutrition Services policy.

• The school or institution may elect to have a pricing or non- pricing program.

• The milk service must be nonprofit and under no circumstances can SMP income be used to subsidize other meals or programs

• Excess funds from the SMP can be used for program improvement and/or to reduce the cost of milk for participants in the SMP

SPECIAL MILK PROGRAM OPTIONS Sponsors must choose and operate one of the following SMP Options in their program

Non Pricing Programs

• Option I- Milk is provided to all children participating in this program free of charge. The cost of milk beyond the federal reimbursement rate is born by the school or institution.

Pricing Programs

• Option II- All children are charged a predetermined price established by the sponsor. The price paid by the children = Cost of Milk - Federal Reimbursement Rate + up to $0.05 (maximum) Administrative fee.

• Option III- Milk is served free to eligible students and sold to others at a reduced rate. The price for milk paid by the children who receive the reduced rate = Cost of Milk – Federal Reimbursement Rate.

COUNTING AND CLAIMING- DOCUMENTATION

The following documentation must be maintained to help substantiate your claims for reimbursement in the Special Milk Program;

• Records supporting the number of milks served daily and claimed for reimbursement

1. daily count sheets for milk served

2. milk used in cooking, spoiled, and served to adults/non program eligible participants

• Daily Attendance rosters for participants in this program

• Milk order documentation such as invoices and delivery records

• Certification documentation for participants in this program where necessary

COUNTING AND CLAIMING- SYSTEMThe counting and claiming system should follow the guidelines listed below;

• The milk may only be counted when it is given to the child at the point of service.

• The eligibility status of each child is transferred accurately to the roster

PROGRAM COMPLIANCEThe Special Milk Program must also meet the following program specific federal regulations;

• Civil Rights

• “And Justice for All” Posters must be prominently displayed

• System for collecting racial and ethnic data for participants in this program

• Civil rights complaint system

• Food Safety

• HAACP Manual with SMP specific SOPs

• Log of weekly milk refrigerator/storage cleaning

• Temperature log for milk refrigerator/storage units

QUESTIONS?

EDUCATIONAL CODES FOR PROFESSIONAL STANDARDS

• Education Codes: 3000 Administration, 3110 Eligibility, 3200 Program management, 3310 Meal counting and claiming, and 3320 Compliance with Regulations